Legal Drafting

110
PARTITION
A SUIT FOR
CIVILJUDGE, SENIOR DIVISION
IN THE COURT OF THE
AT PUNE
ION, PUNE
Civil Suit No......
/20

Shri S1(Full Nanme).

age 32 years, occupation agriculture, Plaintiff
resident of House No. 302 Kothrud,
Taluka Haveli. District Pune.
Versus
1. Shri_F (Full Name).
age 63 years. occupation agriculture,
Smt._M_ (Full Name).
age 55 years, occupation - agriculture,

.
Defendants
Shri_S2-(Full Name).
age 26 years, occupation -

agriculture,
all residents of House No. 302, Kothrud,
Taluka Haveli, District Pune.

A SUIT FOR
PARTITION
Theplaintiff abovenamed submits this plaint, praying to state as follows:
1. The Pedigree: That the
pedigree is as follows:
F (Defendant No. 1)
M
(Defendant No. 2)
S1
(Plaintiff) S2
(Defendant No. 3)
That the defendant No. I
is the father of
3 and husband of the plaintiff and the defendantNo.
the defendant No.
2, while the defendant
of the plaintiff and the No. 2 is the mother
defendant No. 3, and the
are full/real brothers. plaintiff and the No.
defendan
 Legal Drafting

nescription of Properny: All that piece and parcel of land situate within the
2 Division & District Pune, Sub-Division & Taluka Haveli, within the
Registration
lcal limits of the Pune Municipal Corporation, revenue village Kothrud, bearing
admeasuring 8 hectares or thereabouts, and bounded by as follows:
Gat No. 302,
towards the East CTS No. 300,
On or
towards the South CTS No. 299,
On or
the West Public Road, and
On or towards
towards the North Nullah.
On or
described in para 2 above originally belonged to GF, who died
That the property
3. devolved upon the
in June 200, and o his death, the suit property came to be No. I has
of the plaintiff and the defendants, and since then, the defendant
family
the suit property as a Karta of the joint family.
been managing
last one and a half years, the relationship plaintiff's wife
between the
That since and
No. 2 is so strained that there have been frequent quarrels,
and the defendant
for the plaintiff to live apart.
it has finally become necessary to eftect
accordingly called upon the defendant No. 1, on
5. That plaintiff
the
so. to do
partition, but he refused
been obstructing this plaintiffin
submits that the defendants have
That the plaintiff other
with them, and this plaintiff has no
his enjoyment of the
suit property along
save the suit property.
of income except and
source
a notice, dated
served upon the defendants
.

therefore,
That the plaintiff, defendant No. 1, once again,
refused
effect partition, but the
upon them to
calling
to do so, and hence, this suit. Mitakshara School of
defendants are governed by the
8. That the plaintiff and the to one-fourth share in the suit
the plaintiff is entitled
Hindu Law, and accordingly,
when the plaintiff's
property arose on
for this suit first
,

of action been
That the cause
defendants and has since then
the
9

was turned down by limitation.

demand for partition the suit filed today is
well within
thereafter, and hence, of this Court,
arisingevery day local limits of the jurisdiction
is situate within the suit. this
h a t the property
decide
jurisdiction to try and
has that being the
being the
hence, this Hon'ble Court at R s . t h a t
and jurisdiction of of such
valued for the purpose the one-fourth
That the suit is revenue
assessment,
and on
the
ount equal to 20 times
herewith.
court-fee is paid
amount,proper
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112

12. That the plaintiff. therefore. prays that

(A) It be declared that the plaintiff is entitled to one-fourth ch.
share in the
property sun
(B) The plaintiff's one-fourth share be divided and given in his
(C) The defendants be pemanently restrained from obstructing thie Ssession:
his plaintiff
his enjoyment of the suit property:
(D) The plaintiff be paid the costs of this suit from the defendants and
E)
(E) Any other orders in the interest of
justice be kindly passed.
Pune
Sd/-Si
Dated:
PLAINTIFF
Sd/-x Xx
ADVOCATE FOR PLAINTIFF

VERIFICATION
I. Shri S1, the
that the contents of this plaintiff, hereby state on solemn affirmation
present do
plaint paras 1 to 12 are true and correct to
in
my knowledge and belief, and I the best of
have signed hereunder.

Sd/- S1
PLAINTIFF